NJ: Heien reasonable mistake doesn’t apply to an unambiguous statute

Defendant was parked with high beams on on a one way street. The statute unambiguously says that it was not a violation unless there was an oncoming vehicle, and being on a one way street or an officer on foot doesn’t count. Thus, the stop was invalid. This is not a mistake of law under Heien because the statute is unambiguous. State v. Scriven, 2016 N.J. LEXIS 698 (July 20, 2016).*

Defendant did not consent to the PBT test because he wasn’t told of right to refuse, and he passed the field sobriety test. People v. Taylor, 2016 IL App (2d) 150634, 2016 Ill. App. LEXIS 476 (July 20, 2016).*